All other projects disclosed their SEPs only in English, but of the countries with projects in this sample, English is only an official language in Liberia and Uganda. The Guatemala SEP is the only one that has been disclosed in English and Spanish, the country’s official language — it was originally disclosed only in English in April 2020, and a Spanish version was made accessible in November 2020. In Burkina Faso, where the official language is French, all project documents, including the SEP, were disclosed only in English. While it is outside the scope of this project to assess whether ESS7 should apply to projects, seven projects — including in Guatemala and El Salvador — recognize ESS7 as a relevant policy for the projects, and per their ESCPs recognize that there may be Indigenous Peoples among project stakeholders.26 No SEPs have been disclosed on the Bank’s website in Indigenous or local languages. As shown in Table 2, only the Guatemala and Sri Lanka SEPs mention a need for providing specific types of messages and materials in local languages, and the Sri Lanka project is not one of the seven projects for which ESS7 is being applied. The Guatemala SEP indicates that core messages from the World Health Organization and project implementing unit must be disseminated in Indigenous languages, and the Sri Lanka SEP says messages and materials, as well as outreach for stakeholder engagement, will be done in local languages including Sinahala and Tamil. Neither mentions that project information specifically must be disclosed in local languages.27 Beyond disclosing information in relevant languages, all SEPs in this analysis except The Gambia also made a broad reference to providing information in an “appropriate format” and/or that the implementing agencies should provide information that is “understandable and accessible.” Table 2 shows page: The World Bank. “Stakeholder Engagement Plan (SEP) Guatemala COVID-19 Response (P173854) (Spanish),” n.d. https://documents. worldbank.org/en/publication/documents-reports/documentdetail/619451603370586655/stakeholder-engagement-plan-sep-guatemala-covid-19-response-p173854. 26 Five projects’ SEPs list “Indigenous Peoples” as stakeholders under “affected parties” or “disadvantaged or vulnerable” groups, and the Uganda SEP lists specific groups (Iks and Batwas) that are considered Indigenous as stakeholders. While the Bangladesh project ESCP indicates that ESS7 applies to the project and mentions that Indigenous Peoples might be affected by the project, the SEP only mentions “ethnic minorities” as a possible “disadvantaged or vulnerable” group. It is outside the scope of this report to assess whether relevant stakeholders are more appropriately labeled “Indigenous” or “ethnic minorities.” The full list of project countries in BIC’s sample for which ESS7 is relevant is based on their ESCPs: Bangladesh, Nepal, Cambodia, Philippines, Uganda, El Salvador and Guatemala. The ESRSs of Bangladesh and Uganda contradict their ESCPs and indicate that ESS7 is not relevant. 27 Cavagnero, “SEP - Guatemala COVID-19 Project,” 8; Kak, “SEP - Sri Lanka COVID-19 Project,” 11. BANK INFORMATION CENTER | MAR 2021 that only three SEPs in this analysis list specific “appropriate formats” that should be used: Sri Lanka, El Salvador, and Guatemala. The SEP for the project in Sri Lanka provides proposed strategies specifically for disclosing information to “vulnerable groups”, including braille, large prints, text captioning, signed videos, online materials, and multiple forms of communication for persons with disabilities.28 The El Salvador SEP says information should be provided using simple language, illustrations, and translations to make documents easy to understand.29 The Guatemala SEP indicates that sign language, subtitles, and interpreters should be used to make sure patients and their families understand key messages about COVID-19 and the project.30 Thus for all of the projects — except Liberia’s, where the official language is English and for which ESS7 was not determined to be applicable — according to what we can see from the available disclosed documents on the Bank’s website, the Bank and Borrowers have not met the requirements to provide stakeholders with access to project information from the SEP in languages that are relevant and culturally appropriate to them, and do not detail plans to do so for future project information. While almost all of the SEPs recognize the importance of Borrowers making information available in different formats so that they are understood by everyone, especially marginalized groups, all but three SEPs have not provided detail nor shown how this requirement will be met. Groups that don’t have access to information in their local languages may already be marginalized and potentially adversely affected by the projects, and when information is disclosed in languages that are not culturally appropriate for them, they may feel uncomfortable engaging with the project and subsequently may be unable to benefit from it. Per the Directive cited in section A.2, for instance, Indigenous Peoples may have difficulty accessing project benefits, which Borrowers must make accessible to them in an “equitable manner” according to ESS7. Accessing project benefits becomes even more difficult if project information is not offered in formats they understand or in ways that are culturally appropriate and make them feel comfortable engaging with project staff. 28 Kak, “SEP - Sri Lanka COVID-19 Project,” 13. 29 Gordillo-Tobar, “SEP - El Salvador COVID-19 Project,” 5. 30 Cavagnero, “SEP - Guatemala COVID-19 Project,” 7-9. 9